News & Analysis as of

Pay-To-Play Compliance Political Contributions

Skadden, Arps, Slate, Meagher & Flom LLP

Political Contribution Disclosure Rules in Illinois, Maryland, New Jersey, Pennsylvania, Philadelphia and Rhode Island - Update

The following summarizes periodic pay-to-play reporting requirements under laws in Illinois, Maryland, New Jersey, Pennsylvania, Philadelphia and Rhode Island. Certain companies must file reports regarding their business...more

Nossaman LLP

Important Updates to California’s “Pay to Play” Contribution Bans Go into Effect in 2025

Nossaman LLP on

More Action By the FPPC Expected - Introduction to the Levine Act - In 2022, California lawmakers expanded the Levine Act (Government Code Section 84308) to apply to local elected officials....more

Seward & Kissel LLP

A Refresher on the SEC’s Pay to Play Rule

Seward & Kissel LLP on

In the midst of a national election cycle, now is a good time for investment advisers to refresh their understanding on the SEC’s Pay to Play Rule (the “Rule”) and related SEC staff guidance As demonstrated by a number of...more

WilmerHale

Pay-to-Play Alert: Implications of a Governor Joining a Presidential Ticket

WilmerHale on

Vice President Kamala Harris’ selection of Minnesota Governor Tim Walz as her running mate highlights a wrinkle in Investment Advisers Act Rule 206(4)-5 (the “Pay-to-Play Rule” or “Rule”) to which investment advisers should...more

Venable LLP

Political Giving: A Primer for High-Net-Worth Individuals and Family Offices

Venable LLP on

For many years, supporters of a candidate or a cause simply wrote a check and asked friends and colleagues to do the same. But the opportunities to influence elections and public policy have evolved significantly, allowing...more

Proskauer - The Capital Commitment

Key Steps for Fund Managers to Avoid Scrutiny Under the SEC’s Pay-to-Play Rule

The SEC’s recent settlement involving a “pay-to-play” rule violation by a private equity firm is a timely reminder for fund managers, especially with the November elections approaching. As a refresher, Rule 206(4)-5 of...more

Wiley Rein LLP

How to Reduce Your Political-law Risk in Five Easy Steps

Wiley Rein LLP on

Political-law risk is always present, but it becomes particularly acute in even-numbered election years such as 2024. Below, however, we outline five easy steps you and your organization - whether it is a corporation,...more

WilmerHale

Recent Pay-to-Play Settlement: Notwithstanding a Strong Dissent Over 206(4)-5 Overbreadth, the Need for Strong Compliance Policies...

WilmerHale on

With political campaign activity ramping up as the fall elections approach, the Securities and Exchange Commission (SEC) has indicated it will continue stringent enforcement of Investment Advisers Act Rule 206(4)-5 (the...more

Genova Burns LLC

Compliance Corner: Calling all NJ Government Contractors - The ELEC Pay-to-Play Annual Disclosure March 30th Filing Deadline is...

Genova Burns LLC on

New Jersey’s annual pay-to-play filing deadline will be here at the end of March. If your business entity received payments of $50,000 or more (in the aggregate) as a result of New Jersey government contracts during the 2022...more

Wiley Rein LLP

Your First Post-Election Compliance Concern: DC’s New Pay-to-Play Law Operational November 9

Wiley Rein LLP on

With the 2022 general election upon us, it is very important to remember that the District of Columbia’s new pay-to-pay law becomes operational the day after the election on November 9, 2022. Unless your company, partnership,...more

Pillsbury Winthrop Shaw Pittman LLP

Corporate Transactions: Don’t Leave the Political Law Stone Unturned

Especially in an election year, due diligence in corporate mergers and acquisitions is incomplete without reviewing political law compliance. Due diligence often overlooks political law compliance issues, which can result...more

Genova Burns LLC

Political Compliance Calendar for 2022

Genova Burns LLC on

With the new year comes an opportunity to review and re-set the political-law compliance for campaigns, PACs, lobbyists, businesses, and individuals. The following checklist provides a brief overview of upcoming dates on the...more

K&L Gates LLP

Compliance Reminder: Pay-to-Play and the 2020 Election Cycle

K&L Gates LLP on

INTRODUCTION - As the November 2020 elections approach, investment advisers and other financial institutions who do business with, or seek to do business with, public pension plans and other government entities should...more

Pillsbury Winthrop Shaw Pittman LLP

Text, Alexa, Bitcoin—Technology Makes Political Contributions Easier

Is your political compliance program ready for the 2020 election season? With the 2020 election season underway, now is a good time to make certain your internal policies and procedures address applicable campaign...more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2019 Insights: Political Law: What to Consider When Providing Investment Fund Services to US State and Local Government...

With heightened attention to investment and depository rules as well as increased enforcement of federal and state pay-to-play rules, registered investment advisers (RIAs) and broker-dealers should address the unique legal...more

Womble Bond Dickinson

DC Circuit Court Rejects Challenge to SEC Pay-to-Play Rule

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The DC Circuit Court has rejected an effort by the New York and Tennessee Republican Parties to set aside Securities and Exchange Commission Rule 206(4)-5. The 2010 SEC rule prohibits investment advisers from providing...more

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